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My compliments to Prof. J. Parry Lewis on this excellent report, it is what every report should be: clear, understandable, and readable (TDC please take note).
Emeritus Professor
Comment on Local Plan:
Comments on 1. I restrict my comments to areas where I have professional competence. For fourteen years I was professor of the Economics of Regions and Towns in the Department of Town and Country Planning in the University of Manchester. Apart from my academic work I have had considerable consultancy and other experience. In the early seventies I directed the Cambridge Sub-Region Study at the request of the DOE and the relevant Planning authorities.. and was a major expert witness at the Inquiry into the Third London Airport. In the eighties I played major roles in re-organising the Egyptian construction sector.. at the request of the World Bank and in the preparation of a masterplan for Greater Baghdad. I have also had many other involvements. 2. The basic economic message coming from the Local Plan is that the Council would like to see Thanet become more prosperous and more self-contained; with more of its residents employed, and more of them employed locally; with higher incomes and more spending power; and more of that spending done locally. This aim is embodied in four specific targets on page 9 of the Local Plan. Three of them aim at matching Thanet's unemployment rate, average wages and average GDP to those of Kent; and the fourth aims at a specific reduction in the amount of shopping done outside Thanet. 3. While I share the aim embodied in what I have called "the basic economic message", I have doubts about the precise wording of the targets.. and whether pursuing them is the best way of proceeding. While we need to reduce the level of unemployment, and to raise incomes, using comparisons with Kent is not very meaningful. Comparing local statistics with county statistics can be misleading, simply because we are not comparing like with like. 4. Unlike most of the county.. Thanet is a coastal resort outside the London commuting belt. The County's level of unemployment, average wages.. and GDP are all influenced substantially by the fact that a large fraction of Kent's population lives within commuting distance of London. People born in Kent have found work in London or in more local London-dependent establishments; and people working in London have moved to live in Kent. Like Thanet..Kent is far from being self-contained. But unlike Thanet most of it has proximity to London. 5. There is another reason why comparison with Kent averages is misleading. Like many other seaside towns.. Thanet has attracted people who have taken early retirement and are in some cases still registered as unemployed.. or are supplementing their pensions by undertaking part or full time work. .Unemployed people have moved from less attractive locations. And (as the Local Plan makes clear in paragraph 3.89) young people who have been "looked after" have tended to stay as adults forming a dependency culture These factors making the level of unemployment higher than it would otherwise be also exist at other coastal resorts in Kent, but most of these have greater proximity to London, which works in the opposite direction. The same factors also exist in coastal resorts throughout the country, and especially in the South. A study of the experience of these resorts, and an analysis of their statistics, would provide a better basis for the setting of Targets and Policies than the not very meaningful comparison with Kent. Why not list employment and wage rates in coastal towns throughout the South (perhaps excluding those within an hour's train journey of London, or very different in size from Thanet ) and aim at getting Thanet into the top quarter of the lists, or even higher? - 6. Paragraph 1.11 mentions that 11.000 people living within Thanet travel every day to work outside it, but only 2000 people come from outside to work Thanet ---a ratio of 11 to 2.. If we are taking Kent as a standard, it is pertinent to enquire what the ratio is for Kent. Simply because it is a much bigger area, Kent is likely to have a lower ratio than Thanet, but proximity to London will distort it. 7. In any case for small urban areas this kind of approach to journey-to-work statistics is not very useful. How much of the imbalance is because people with jobs outside Thanet decide to live in Thanet, as a pleasant place with low property values? How much of it arises from people whose work journey is very short but happens to cross a local government boundary. to a place such as Pfizers? The boundaries of the natural labour market rarely co-incide with local government boundaries. 8. I support the aim of providing more shopping opportunities within Thanet at a central location, on a limited scale. However much we need better opportunities for some kinds of shopping, we also need our existing town centres. These matter and will not survive simply on ( often empty?) restaurants and small shops. They have already lost some multiples that have moved to the Westwood area. Many of the new jobs "created" there will be taken by residents who now work in Canterbury or the old centres. The challenge is to provide better central facilities while also encouraging more people to shop in the existing centres. Leisure opportunities. tourism, car-parking policies must all play their parts. 9. An important point concerns the impact of new shopping development on the local recycling of income. The takings of a local independent shopkeeper are disbursed in various ways. Apart from the wages paid to the staff there are payments to suppliers (some of whom may be local), to various professional people, such as accountants ( who may also be local) and to insurance companies (who may operate through a local agent). The shopkeeper may own the property. If it is rented there is quite a chance that the owner is a local person. In fact, except for fuel payments, all the disbursements ( other than taxes) may well be at least in part to other local people, who will spend locally once more. This will pay for more local jobs, and the newly employed will in turn spend some of their money locally, generating further jobs, and so on. Spending at a locally owned independent shop has a high degree of income re-cycling, which means that the standard income multiplier mechanism will increase the number of jobs and push up the local GDP . 10. On the other hand spending in a multiple results in some recycling through wages. and very little else. Rents are likely to go to national landlords. Supplies are very unlikely to come from local producers. The accounts are likely to be prepared by a national firm; and so on. A flourishing shopping centre tenanted by mutliples is a sink draining money out of the local economy. Shifting spending from a privately owned shop to a multiple will mean that more money is going permanently out of the pockets oflocal people. 11. This is a good reason for helping independent shops to remain economically viable. Another is that privately owned shops often provide a higher degree of service and a wider variety of good than do the multiples. (Try getting a multiple to consult wholesalers' catalogues and place a special order!) 12. Three ways in which the Council can do this come to mind. One is not primarily a land-use planning issue, but it has planning implications. As part of Corporate Planning the Council should encourage local people and organisations (including the Council itself) to buy from locally owned independent shops. 13. A second way, of more concern to planners, is to encourage those people who are in any case going to use their cars for shopping to buy from independent shops and existing centres. I agree with charging for on-street parking (paragraph 4.100 ), but the charges should be levied in a way that makes them trivial for the first hour. Out-of-town multiples offer free car parking, thereby enticing shoppers away from the in-town independents. Car parking charges in town centres work in the same direction. Shops have overheads that cannot easily be adjusted to the volume of business. This means that a fall of just a few percent in the takings will often be enough to turn a net profit into a net loss, and to lead to closure. Insensitive car parking charges can have exactly that effect. There is indeed a strong case for trying to impose charges on cars parked in supermarket and similar car parks, both in the interests of the little shops and as part of a green policy. 14. A third way to encourage spending in independently owned outlets is for the Council to make the following amendments to its Objectives and Policies: Paragraph 4.71, Objectives: Add (5) THAT THE DESIRABILITY OF ENCOURAGING LOCALLY OWNED SHOPS AND OTHER OUTLETS SHOULD BE EMPHASISED. Policy TC6. I. Add AND ON THE RECYCLING OF INCOME. Policy TC7. Add ...AND THROUGH THE ENCOURAGEMENT OF LOCALLY OWNED SHOPS AND LEISURE OUTLETS Policy TC8 .Insert after "FACILITIES" , DO NOT ADVERSELY AFFECT THE RECYCLING OF INCOME Targets. Amend to include "NUMBER OF LOCALLY OWNED SHOPS" and "INCREASE THE PERCENT AGE OF RETAILING INCOME RECYCLED". 15. As part of my interest in the recycling of income, I suggested to the Council several years ago that it might take a lead in encouraging the local manufacture of things for local sale. For example, many of the souvenir and other shops near the sea fronts sell items that have been purchased from outside the area but could well be made locally, with a higher percentage of tourist spending finding its way into local pockets. Many unemployed residents are perfectly able to make saleable items ranging from rag dolls or fancy hats and the like to more serious craftwork. The problem they face is marketing. If there were an organisation ( called "Things from Thanet" ?) that would pay for these items and then sell them to retailers a considerable cottage industry could develop and eventually it might even export to other areas. At a different scale there seems to be no reason for not making many garden ornaments, fancy walling materials and fencing. and marketing them through the same kind of organisation. Thanet could lead the way in the development of local production for local markets. 16. While income-recycling can bring greater prosperity to Thanet, the major task must be encouraging tourists and others to spend more money here, preferably with local people. Much has been done to draw visitors, and there are some exciting on-going schemes, but we still need a need a really major attractor of young people. Could Thanet become a regional centre for skating and other all-year activities? Could European or Lottery money help to fund a really top-class venue for concerts, stage competitions and indoor sports contest? If Thanet is to be much higher on the list of economic indicators for seaside towns it must attract many more visitors who will look upon it as an essential place to visit, and an attractive place at which to stop. 17. Providing premises for restaurants is no good unless the restauranteur can see a real customer potential; and that has to be attracted by other means. One possibility is the creation of large Exhibition of Britain. It could be based on a large physical model of the country showing its main features and attractions.. with separate large scale models of historic and other towns.. augmented by exhibitions organised by local tourist boards.. restaurants serving regional dishes, a folk museum and other features. In time it could develop son et lumiere pageants. Any visitor to the country.. and especially those arriving at Dover who now drive west as soon as they can., would be encouraged to linger in Thanet for long enough to have a taste of Britain.. and then perhaps to see what else is on offer in Thanet. 18. When I put this idea to the Council some years ago it ended up on the desk of an officer who was preoccupied with the organisation of a cartoon exhibition, which seemed to me to be a different level of thinking. I think that now we have a Council more capable of taking big and bold initiatives.. and possibly more able to attract funds for such a venture. 19. More tourist expenditure in Thanet and higher income recycling are the essential planks upon which a stronger and more self-contained local economy must be built. But, despite the claims that have been made for it.. if we are not very careful expansion of the airport will work in the wrong direction. In paragraph 5.27 we read that the airport offers "very significant economic and employment benefits for Thanet and East Kent". There is nothing about its disbenefits. But as I show below, its job-creation potential has been exaggerated and its serious negative impacts on incomes and tourism have been virtually ignored. I believe that if the airport is allowed to develop in the way that now seems likely it will be seen by posterity to have been a major mistake. This unpopular view has to be explained. 20- Figures of prospective employment at the airport have been based on an assertion that "research" has produced a "rule of thumb" that for every million passengers per annum there will be about 1,000 jobs; and for every 100,000 tons of freight a similar number of jobs. 21. I have looked very carefully into this and can find very little evidence of respectable research or of fact to substantiate the rule of thumb. I am increasingly of the opinion that it is a myth which has gained acceptance simply through repetition. However BAA's recently published Issues Brief entitled "Stansted growing sustainably" must cause even its strongest. adherents to think again about the ratio of 1000 jobs to every million passengers embodied. in the rule of thumb. It reports that Stansted airport currently "handles around 12 mppa" but "employs 9,500 people", or rather fewer than 800 employees per million ppa.. There is no reference to how much of the employment arises from freight. It goes on to say that this employment figure "would increase to around 16,000 were the airport to increase to about 25 mppa. " Thus an increase of 13 million passengers would result in an increase in on-site employment of 6,500 people rather than the 13,000 predicted by the rule of thumb. These figures relate to "direct employment", which is defined as "that which is wholly dependent on airport-related activities whether on site at the airport or off-site". How many of these people would be working only part-time or simply in the peak periods is not revealed. 22. In paragraph 2.64 the Draft Local Plan states that the Council will plan for 150,000 tons of freight per annum by the year 2011, and for 1,000,000 passengers per annum. If we adopt the discredited rule of thumb these amounts of passenger and freight traffic would generate direct employment of 2,500 persons. 23. On page 29 the Draft Local Plan sets out a target of 1,000,000 passengers, 100,000 tons (not 150,000, as in the last paragraph) of freight and 3,500 jobs, instead of the 2000 produced by the rule of thumb. Since the rule of thumb concerns total direct employment, we must suppose that the difference between the target and rule of thumb figure arises from activities that are not wholly dependent on airport-related activities. Is this correct? How has the figure been estimated? 24. Thus there are questions about the estimates and targets even if we accept the rule of thumb. If we do not accept it, but use a ratio based on the BAA figures, the level of direct employment associated with the target figures for freight and passengers seems to be more likely to be about 1600. This must be taken with the caution that many of these will be seasonal or part -time, and many taken by people who move in from other parts of the country .These British immigrants will often bring partners with them, and most of these partners will swell the number of job-seekers. If 1600 jobs are created and (say ) 400 of these go to immigrants with job-seeking partners the net gain in jobs available to local residents is reduced to 800. It is this kind of figure that should form the basis of policy decisions. (This is lower than I have suggested elsewhere mainly because the Council has set a target at a lower level.) 25. As a result of the increase in employment at Manston, as with all other increases in employment, there will be more money to spend in shops and other retail outlets, creating more jobs. Most of this money will be spent in the home towns of the workers, which means that not all of this "upward multiplier effect" will be felt in Thanet. In particular, itinerant construction workers and seasonal workers may well spend very little in Thanet. Many of the seasonal workers will be students and others who take summer employment to help them with their costs in the rest of the year. Little of the money paid to them will appear as re-cycled income in Thanet. The induced (or multiplier effect) employment will be correspondingly lower. There will also be a negative impact on incomes and employment, and this could eventually become the dominant consequence of the airport, as we see below. 26. Tourism is Thanet's major industry, and the economy of Thanet still depends heavily on spending by visitors, ranging from day trippers (who are markedly fewer now that there is.no passenger ferry) to holiday makers and longer term visitors such as students at language schools. A great deal ofwork is being done in an attempt to attract them. The Draft Local Plan reports that in 1998 spending by English language students in Thanet amounted to £27.15 million. This amount of spending is roughly equal to the incomes of maybe 2000 workers and has a high local recycling potential. 27- Many visitors stay overnight, often in hotels and guest houses that are under the flight path, as indicated very roughly by the 57dB(A) noise contour in the Airport Noise Contour Map published in the Draft Local Plan. This takes no account of night flights. Quite ordinary houses take in students throughout the year and holiday makers, especially in the summer. If air traffic grows to the predicted levels, noise is going to drive away many of these visitors, especially if there are many night flights- Holiday visitors adjust less easily to aircraft noise than do residents. Losing sleep at night, and finding that aircraft noise mars even their day-time enjoyment of the beaches, they will look for quieter seaside resorts, and they will advise their friends to do the same. Students at language schools will not only be kept awake at night, but many of them will also find that their lessons are interrupted by the noise of planes passing low overhead. This is already happening- They, too, will advise their friends to go elsewhere. There are plenty of quieter places in the south where guest houses and language schools flourish. 28. Once Ramsgate gets the reputation for being noisy, exaggeration will quickly kill its visitor industry .The loss of income by hotels and landladies will lead to the employment of less help, Their spending in shops, both on food for their visitors and on other items will fall. . Shops and restaurants will also have less business from the visitors themselves. This will ultimately affect the level of employment in some of them. In some cases, shops that have been struggling to remain viable may be forced to close, affecting the trade of neighbouring shops. In retailing closures become infectious. Landladies will also have less to spend on the employment of local tradesmen and craftsmen, such as plumbers and decorators, who will employ less help. There will be a downward multiplier effect, and I believe that this will eventually outweigh the upward effect mentioned above. 29. Although this will be at its worst in Ramsgate, some adverse effects on employment will also be experienced further a field. For example, students at language schools and other visitors will return home and report not that central Ramsgate is noisy by day and by night, but that this is true of Thanet and north east Kent- They will advise their friends to have their holidays or learn English in other parts of south-east England, thereby affecting businesses and landladies throughout the whole area. Bad reputations are easily, and often unfairly, acquired. 30. Noise will also affect house prices. This will be especially so under the flight paths, but there will also be substantial effects elsewhere. Conditions will be worsened by the effects of vibration and pollution from low flying planes. A great deal of public money (some of it European) is being spent on preserving and enhancing the structures and appearance of conservation areas. There is also a national policy to make deprived areas more attractive. But every time a large plane descends over Ramsgate buildings in these areas are shaken, window frames and decorative and functional iron and stone work vibrate, pollutants fall on roofs and walls and insidious non-attributable decay is set in motion. The older buildings. many of them listed (such as those shown enticingly on the cover of the Draft Plan) will be the first to show the signs. Many of the present occupiers will not be able to afford to move, especially when negative equity arises, and, as houses become unsellable, decay will set in. 31. Summing up, jobs will be lost as tourism and language schools decline, landladies and hoteliers lose income, and shops and other traders are hit. House owners see the values of their houses fall and many are be unable to sell. The decaying town attracts fewer and fewer visitors, and fewer and fewer businesses. It is easy to reject such arguments as unsubstantiated by statistics, but statistics relate to the past. A function of planning is to think about the future, and about how people react, or will react, to pressures of different kinds. We already have evidence from the experiences of Heathrow and other airports, but none of these is so close to a town whose present economy depends heavily on visitors. People have already moved from the town centre area under the flight path because of present aircraft noise and the expectation of more noise; and potential purchasers have lost interest after examining the position of the flight path.. Waiting for more evidence means waiting until it is too late. 32. This grave and very real threat that aircraft noise poses to our economy has been completely ignored in the Draft Local Plan. Noise is looked upon simply as a nuisance imposed on residents under the flight path, and its impact on visitors of various kinds, and on businesses and employment is not considered. It is time to remedy this. 33. At the moment the Council's attitude towards the airport is based on a mistaken impression of its worth as a creator of jobs and a failure to appreciate the economic harm that its expansion will bring. For example, on page 18 of the Draft Local Plan, paragraph 2.51 explains that the Council is "conscious of' the "concerns of those who live under the flight path" and is "mindful of the environmental consequences"; but there is no reference at all to the wider economic consequences of noise, or the impact on tourism--- Thanet's major industry. The next paragraph talks of balancing the operational requirements of the airport " against the genuinely held environmental concerns of those most affected. " But the balancing should also take into account the wider economic consequences over an area much larger than "under the flight path" 34. The same failure to take account of wider economic and social issues is illustrated in other places. For example, on page 20 POLICY EC3 , paragraph 4 ends with the Statement that THE ACCEPTABILITY OF PROPOSALS WILL BE JUDGED IN RELATION TO ANY IDENTIFIED NOISE IMPACTS. THE EFFECTIVENESS OF MITIGTION MEASURES AND THE SOCIAL AND ECONOMIC BENEFITS OF THE PROPOSALS. But there is no reference to the disbenefits, or costs. Indeed there is no evidence that these have been thought about other than as noise affecting people who live under the flight path. This POLICY should be amended by inserting AND COSTS (or AND DISBENEFITS) after the word BENEFITS. 35. Similarly Paragraph 3 of POLICY EP1, on page 206. Paragraph 3 says that "REGARD WILL BE PAID TO THE ECONOMIC AND WIDER SOCIAL NEED FOR THE DEVELOPMENT ." The general tone of the document makes it clear that the dominant factor in this evaluation will be the asserted level of job-creation. But if Paragrapah 3 is amended by replacing NEED FOR by CONSEQUENCES OF. to read (3) THE ECONOMIC AND WIDER SOCIAL CONSEQUENCES OF THE DEVELOPMENT ..." then factors such the impact on tourism, and the impact of that on local business and employment would have to be taken fully into account, as they should be. 36. The principal instrument of control over activities at the airport is the Section 106 Agreement negotiated between the Council and the developer. The first draft agreement, published in March 2000, struck many people (including myself) as being far too favourable to the developer. In light of comment it was considerably improved, but there are still too many opportunities to circumvent it and in any case it fails to address adequately two main issues: the number of flights in a 24 hour period and night flights. Since the Council intends to have a series of Section 106 agreements (paragraph 2.55) it should embody in its TARGETS the IMPROVEMENT OF CONTROLS OVER THE AIRPORT, THE SETTING OF AN UPPER LIMIT ON THE NUMBER OF FLIGHTS IN ANY 24 HOUR PERIOD, AND THE CESSATION OF NIGHT FLIGHTS; and POLICIES should be amended accordingly. Unless this is done the adverse economic impact on tourism and other features of the economy will cause Ramsgate to decay and the whole of Thanet to suffer as a consequence. 37 It is also necessary to state clearly what happens after a noise-assessment or impact study has been received., and how decisions are to be influenced by the studies. This statement should be set forth as a POLICY. 38. One of the problems facing those who try to attract firms to any area is showing that there is an adequate supply of skilled or trainable potential employees. There seems to be little attention to this. Would it be a good idea to give favourable consideration to developments that have associated support for training schemes? . 39. As a seriously disabled driver I would like to see a more overt attention to the problems of providing for disabled drivers when introducing parking controls and pedestrianisation schemes. There also needs to be more concern for people who may not be registered as disabled but are unable (perhaps because of age) to carry shopping to car-parks. A few very short stay parks dedicated to customers of specified shops might be a practical partial solution.
J. Parry Lewis |